rendering of any technical or consultancy services (including the provisions of services of technical or other personnel) which :
(a) are ancillary and subsidiary ... rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services
.....
(b) make available technical
rendering of any technical or consultancy services
(including through the provision of services of technical or other personnel) if
such services:
(a) are ancillary ... make available technical knowledge, experience, skill, know-how or
processes, or consist of the development and transfer of a technical plan or
technical design
engineering service,
software development and in connection with which payments were made to foreign
companies for availing their technical knowledge and technical services. Having regard ... this context services requiring expertise in a technology. By consultancy services,
we mean in this context advisory services. The categories of technical and consultancy
services
Technical Services'.
(2). Management Support Services Agreement dated 22.10.2001 with Philips India Ltd
on account of 'Fees for Technical Services'.
Since ... which is reproduced as under:
ARTICLE 12 - Royalties and fees for technical services -
1. .......................
2.........................
3........................
4. The term 'royalties' as used
disputed only the transactions of payment of Royalty and Fees for technical services,
whose ALP has been determined under the CUP method, thereby impliedly accepting ... international transactions of payment of royalty and fees for technical services. He
urged that these two international transactions ought to have been considered along
with
services ;
Management Information services , System Development Communication
Services , Engineering Services Tool design services , manufacturing services,
capital planning and inventory managing services , procurement services,
advertisement services ... Computer Usage, Communication Services,
Engineering . Services, Crosses and Tool design services, Manufacturing
Services, Capital Planning and Inventory Management Services ,Mettallurgical
Services, RGI , Quality Assurance Services
services ;
Management Information services , System Development Communication
Services , Engineering Services Tool design services , manufacturing services,
capital planning and inventory managing services , procurement services,
advertisement services ... Computer Usage, Communication Services,
Engineering . Services, Crosses and Tool design services, Manufacturing
Services, Capital Planning and Inventory Management Services ,Mettallurgical
Services, RGI , Quality Assurance Services
payment in question being in
the nature of "Fees for Technical Services rendered" in para 21 of the CIT(A)'s order ... term
'literary work' includes computer programs, tables and compilations including
computer data base. Therefore, the computer software has been recognized as a literary
resident manufacturer along with a computer or computer-based equipment under any scheme approved under the Policy on Computer Software Export, Software Development and Training ... individual for independent personal services mentioned in Art. 15 (independent personal services) , in consideration for services of a managerial, technical or consultancy nature, including
rendering services from the UK, the Assessee had obtained certain services
from M/S.Appledore, an independent sub-consultant. The services in India
were rendered ... rendered services and raised invoices on GRSE
separately, for services rendered outside India and services rendered in India. The
local services had been rendered only
